The Gujarat Authority for Advance Ruling (GAAR) has held that a wide range of training and awareness programmes conducted by a registered charitable trust for government departments qualify for Goods and Services Tax (GST) exemption under Notification No. 12/2017-Central Tax (Rate). However, the Authority clarified that organizing blood donation camps and conducting road safety training do not qualify as “charitable activities” for GST exemption. 

The advance ruling application was filed by a Gujarat-based charitable trust registered under the Bombay Public Trust Act, 1950, and under Section 12AB of the Income Tax Act. The trust sought clarity on the GST treatment of various educational, vocational, health awareness, and skill development programmes conducted under government schemes. 

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National Mental Health Programme Exempt from GST

The Authority ruled that services provided under the National Mental Health Programme (NMHP) are exempt from GST under Entry No. 1 of Notification No. 12/2017, provided the trust possesses a valid registration under Section 12AB of the Income Tax Act.

GAAR observed that the activities undertaken by the trust—including reducing stigma surrounding mental illness, conducting awareness programmes, training ASHA and Anganwadi workers, organizing public education campaigns, exhibitions, and community outreach—constitute charitable activities aimed at advancing educational programmes for mentally traumatized persons. Consequently, such services fall squarely within the exemption available to charitable institutions. 

Self-Defence Training for Women Held Exempt

The Authority also granted GST exemption to self-defence training programmes conducted for women and girl students under work orders issued by the Gujarat Police and the Education Department.

The ruling noted that these programmes are implemented under the Suraksha Setu Programme and other government initiatives, with the entire expenditure borne by the State Government. Since the services are provided directly to State Government departments under government-funded training programmes, they satisfy the conditions prescribed under Entry No. 72 of Notification No. 12/2017. 

PM Vishwakarma Skill Training Also Qualifies

GAAR further ruled that training imparted to goldsmiths and artisans under the Pradhan Mantri Vishwakarma Scheme is exempt from GST.

The Authority observed that the applicant had been appointed by the Gujarat Matikaam Kalakari and Rural Technology Institute to conduct artisan mobilisation and skill development under the Central Government-funded PM Vishwakarma Scheme. Since the scheme is fully financed by the Government of India, the training services qualify for exemption under Entry No. 72. 

Vocational Training in Kasturba Gandhi Balika Vidyalayas Exempt

The ruling also extends GST exemption to vocational training programmes conducted in Kasturba Gandhi Balika Vidyalayas (KGBVs).

The trust had been engaged to provide taekwondo and tailoring training to students in government-supported residential schools for girls. GAAR held that these schools are funded through government grants, and therefore, the services constitute government-funded training programmes eligible for exemption under Entry No. 72. 

Yoga Camps Covered as Charitable Activities

Another significant aspect of the ruling relates to yoga camps conducted by the trust.

The Authority observed that advancement of yoga is specifically included within the definition of charitable activities under Notification No. 12/2017. Accordingly, yoga camps conducted by a trust registered under Section 12AB remain exempt from GST, subject to continued validity of the Income Tax registration. 

De-addiction and Sanitation Awareness Programmes Exempt

GAAR further held that seminars on de-addiction from tobacco and drugs and training programmes on cleaning and sanitation qualify as charitable activities under the category of preventive healthcare.

According to the Authority, these programmes promote public awareness regarding disease prevention and public health, thereby satisfying the statutory definition of charitable activities. Such services are therefore eligible for GST exemption under Entry No. 1 of the exemption notification. 

Blood Donation Camps Not Covered

However, the Authority rejected the trust’s contention that blood donation camps constitute preventive healthcare.

It observed that although donors undergo basic health screening before donating blood, the primary purpose of such camps is to collect blood for medical emergencies rather than to prevent disease. The ancillary medical examinations carried out before donation cannot transform the activity into preventive healthcare.

Accordingly, blood donation camps were held to be outside the scope of charitable activities and therefore not eligible for GST exemption. 

Road Safety Training Also Taxable

Similarly, GAAR ruled that road safety training programmes are not covered under the definition of preventive healthcare.

The Authority reasoned that preventive healthcare is aimed at preventing diseases, whereas road accidents and traffic injuries cannot be equated with diseases. Consequently, road safety awareness programmes do not qualify as charitable activities under Entry No. 1 and remain liable to GST. 

No Ruling on Certain Vocational and Agricultural Training

The Authority declined to answer questions concerning vocational training, computer and ITI training, as well as training provided to agriculturists.

It noted that the applicant had failed to furnish adequate work orders, agreements, or sufficient details regarding the nature of services and recipients. In the absence of complete factual records, the Authority held that no advance ruling could be issued on these issues. 

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